JUDGMENT T. R. Handa, J.—The petitioners are engaged in the business of manufacture of steel ingots from old iron and steel melting scrap as also from imported steel melting scrap which manufacturing process they are doing with the aid of electric furnance. For this purpose they are running a factory in Una under the name and style of Mittal Udyog.’ 2. Hitherto the petitioners have been paying excise duty on the steel ingots manufactured by them in terms of Tariff item No. 26 of the First Schedule attached to the Central Excise & Salt Act, 1944, hereinafter referred to as the Act. The contention of the petitioners is that they had been paying such excise duty under a mistaken conception of law as on a true interpretation of the relevant provisions of Section 3 of the Act read with Tariff item No. 26 of the First Schedule thereto, no such excise duty is leviable on the manufacture of steel ingots from out of steel melting scrap. The petitioners accordingly vide their representation dated 26-12-1980 addressed to the Superintendent, Central Excise & Customs with copies to Inspector Central Excise Una and Assistant Collector, Central Excise & Customs, Chandigarh disputed their liability to pay excise duty on the steel ingots manufactured by them. A copy of this representation is found at Annexure P. 1. The stand taken by the petitioners was, however, not accepted by the Excise Authorities according to whom the item of steel ingots manufactured by the petitioners was very much chargeable to excise duty as the same fell under Tariff item No. 26 of the First Schedule attached to the Act. The Excise Authorities accordingly repudiated the stand taken by the petitioners that they were not liable to pay the excise duty and vide their letters found at Annexure P. 2, P. 3, P. 5, P. 8, and P. 9, the various authorities of the Central Excise & Customs Department called upon the petitioners to continue paying the excise duty on the steel ingots manufactured by them as before failing which they would be liable for the contravention of the Excise Rules. 3. 3. The petitioners have now approached this Court-under Article 226/227 of the Constitution praying for issue of an appropriate writ, direction or order for quashing the notices found at Annexures P. 2, P. 3, P. 5, P. 8, and P. 9 and further restraining the respondents from demanding any excise duty from the petitioners in respect of the steel ingots manufactured by them. The petitioners have further prayed for issue of a direction to the respondents to refund the excise duty already paid by them as per statement: found at Annexure P. 10 attached with the petition. They have also prayed that the respondents be directed to refund any other amount which the petitioners might have to pay by way of excise duty in addition to what has been stated in the statement Annexure P. 10. 4. The short question which, therefore, falls for consideration in this writ petition is whether the steel ingots which are admittedly being manufactured by the petitioners out of the old iron and steel melting scrap and imported steel melting scrap are chargeable to excise duty in terms of the provisions of Section 3 of the Act read with Tariff item No. 26 of the First Schedule to the Act. 5. Now it cannot be disputed that the Act levies a duty called Excise Duty, on all excisable goods produced or manufactured in India [See Section 3(1) of the Act] The term excisable goods has been defined in Section 2(d) of the Act to mean goods specified m the First Schedule as chargeable to excise duty and includes salt. It, therefore, follows that excise duty is leviable on the production or manufacture of any specie of goods which has been specified in the First Schedule of the Act as chargeable to excise duty. The item Steel ingots which the petitioners are manufacturing is covered by Tariff item No. 26 of the First Schedule which is as follows: Item No. Description of goods Rate of duty. 26 Steel ingots including steel melting scrap Three hundred and fifty rupees per metric tonne. The steel ingots, therefore, do fall within the definition of excisable goods and manufacture of this item in India would, therefore prima facie attract levy of excise duty under the Act. To this extent the parties are in complete agreement. 6. 26 Steel ingots including steel melting scrap Three hundred and fifty rupees per metric tonne. The steel ingots, therefore, do fall within the definition of excisable goods and manufacture of this item in India would, therefore prima facie attract levy of excise duty under the Act. To this extent the parties are in complete agreement. 6. The ground on which the petitioners dispute their liability to pay excise duty in respect of the steel ingots prepared in their factory in short though not simple. Their argument is that the process of converting steel melting scrap into steel ingots in which process they are engaged, does not amount to manufacture of steel ingots for the purposes of levy of excise duty under the Act inasmuch as excise duty under the Act is leviable only on the production or manufacture of excisable goods. The petitioners who do not manufacture steel ingots are not liable to pay such excise duty. 7. The term manufacture implies and means transformation by treatment, labour and manipulation of a given substance or a number of them put together, into a new and different substance having a different name, character and use. The parties are not at variance with respect to the above meaning and interpretation of the term manufacture. 8. It is also not disputed on either side that for converting steel melting scrap into steel ingots, the scrap has first got to be melted by heating it in a furnance and then moulded into ingots. It again is admitted on either side that in common parlance as also in the relevant trade circles, steel melting scrap and steel ingots are treated as two distinct and different commodities and that they have different characters and uses. Ordinarily, therefore, the conversion of steel melting scrap into steel ingots must amount to a manufacturing process as it admittedly has the effect of bringing into existence a new substance quite different from the one out of which it is produced. 9. Ordinarily, therefore, the conversion of steel melting scrap into steel ingots must amount to a manufacturing process as it admittedly has the effect of bringing into existence a new substance quite different from the one out of which it is produced. 9. The contention of the petitioners, however, is that though in common parlance and trade circles, steel melting scrap and steel ingots are treated as different commodities and they have different characters and uses, the Parliament by using the language as is found in column No. 2 description of goods against Tariff item No. 26 of the First Schedule to the Act, enlarged the meaning of steel ingots so as to include steel melting scrap as well. To be precise, the argument is that by fiction of law, steel ingots and steel melting scrap, inspite of their different trade names, charactars and uses, are to be treated as one and the same substance for the purposes of levy of excise duty under the Act. It being so the conversion of steel melting scrap into steel ingots would not amount to bringing into existence any new or different substance and hence this conversion would not amount to manufacture. In support of this argument the learned counsel for the petitioners relies upon the following observations made by the Supreme Court in Commissioner of Income-Tax, Andhra Pardesh v. Taj Mahal Hotel [(1971) 82 ITR 44] regarding the nature and scope of the word includes : "The word includes is often used in interpretation clauses in order to enlarge the meaning of the words or phrases occurring in the body of the statute, When it is so used, these words and phrases must be construed as comprehending not only such things as they signify according to their nature and import, but also those things which the interpretation clause declares that they shall include". As already observed the language used in column No. 2 of the First Schedule under the head description of goods against Tariff item No. 26 reads "steel ingots including steel melting scrap". The use of the word including according to the learned counsel for the petitioners, means that steel ingots and steel melting scrap are to be treated as one and the same substance and that if one is converted into the other, it would not amount to emergence of a new substance. 10. The use of the word including according to the learned counsel for the petitioners, means that steel ingots and steel melting scrap are to be treated as one and the same substance and that if one is converted into the other, it would not amount to emergence of a new substance. 10. This argument ignores the fact that the language employed in column No. 2 against Tariff item No. 26 of the First Schedule is not intended to define or interpret the term steel ingots or steel melting scrap. Column No. 2 of the First Schedule is under the caption description of goods. Under this column, therefore, only specified goods have been described, which goods in view of the definition clause as found in Section 2(d) are called as excisable goods. The only reasonable interpretation of the language used in column No. 2 of the First Schedule against item No. 26 is that both the steel ingots as also steel melting scrap are chargeable to excise duty at the rate mentioned against this item in column No. 3. Both these substances were included against item No. 26 for the simple reason that the rate of excise duty for the manufacture of either of them was the same, namely, three hundred and fifty rupees per metric tonne. In this connection reference may be made to item No. 34 of the First Schedule. The language used in column No. 2 against this item reads: "motor vehicles and tractors including trailers". The word including was naturally used by the Legislature in the same sense in both these entries, viz. enteries No. 26 and No. 34. In case this word "including" is interpreted in the manner in which the learned counsel for the petitioners wants it to be interpreted, it would amount to saying that the Parliament intended that Motor Vehicles, Tractors and Trailers should all be treated as one and the same substance for the purposes of levy of excise duty. This, however, just cannot be accepted. The term "Motor Vehicles has been separately defined in column No. 2 against item No. 34 which reads "motor vehicles means all mechanically propelled vehicles, other than tractors, designed for use upon roads". This, however, just cannot be accepted. The term "Motor Vehicles has been separately defined in column No. 2 against item No. 34 which reads "motor vehicles means all mechanically propelled vehicles, other than tractors, designed for use upon roads". The giving of definition of the term Motor Vehicles after the description "motor vehicles and tractors including trailers" given in column No. 2 of item No. 34 clearly shows that the aforesaid description is not intend to define the term Motor Vehicles or any other term as used in this column of description. Otherwise also, a trailer which is not mechanically propelled vehicle would not fall within the definition of the term Motor Vehicles. Item No.34 thus itself recognizes that motor vehicle and trailer are two different substances. The use of the word including there obviously does not have the effect of treating the commodities mentioned before and after this word as one and the same commodity. Wherever it was intended to define or interpret a particular word or term, a separate defining clause has been added to the relevant provision of the Act. It is not, therefore, correct to say that the language employed in column No. 2 of the First Schedule against item No. 26 defines or interprets the term steel ingots as including steel melting scrap. Both these substances have different names, characters and uses and by describing them together against a single entry of the Schedule, the Parliament only intended to lay down that either of them in chargeable to excise duty. 11. The argument put forward on behalf of the petitioners, therefore, cannot be accepted. In the result, I must hold that steel ingots and steel melting scrap are two different commodities and that conversion of steel melting scrap into steel ingots by the process in which the petitioners are engaged doss amount to manufacturing of steel ingots so as to attract levy of excise duty under the Act. This writ petition is thus without force and is dismissed with costs. Petition dismissed.